Back in active blogging "mode" here on the campus of the Sweet 16 bound Butler Bulldogs after an enjoyable few days in Washington D.C. where I participated in Georgetown Law's Combating Global Corruption Conference. It was nice to see some familiar faces, connect faces to some names I have met through this blog, and to meet new people. The title of my presentation and upcoming paper in the Georgetown Journal of International Law is "The Facade of FCPA Enforcement" and I will post in the coming days a short abstract of the paper as well as my presentation slides.
In the meantime, some items of note.
Africa Sting
Christopher Matthews at Main Justice continues to follow the Africa Sting case and has this report of yesterday's hearing.
Shearman & Sterling Update
Shearman & Sterling pioneered the concept of keeping track of FCPA enforcement actions in an "FCPA Digest" (see here) and it supplements the digest with occasional "Recent Trends and Patters" update. For the latest, see here from Philip Urofsky & Danforth Newcomb.
FCPA Compliance in Phnom Penh
Looking for additional evidence that the FCPA is indeed a hot topic. How about this article from Phnom Penh Post of Cambodia. As noted in the article, a recent FCPA seminar, hosted in part by the American Chamber of Commerce, attracted more than 100 local business leaders.
I wonder if anywhere in the discussion of Siemens and/or BAE the point was made that neither of these entities were charged with FCPA antibribery violations?
Further, I remain perplexed by the curious (and frequent) tendency of FCPA conferences including representatives from FCPA violators - a regional compliance officer for Siemens Singapore presented at the seminar.
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I'm not sure why the inclusion of a representative from a violator would be considered curious. In my experience at such conferences the representatives (who uniformly were not employed by the company during the violation period) have very valuable insights into 1) managing an investigation/disclosure process and 2) implementing a robust, government-approved compliance and auditing process.
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